Applying – Out-of-State Licensees

Applying – Out-of-State Licensees

Applying for License Based on License in Another State – “Licensure by Endorsement”

Editor’s Note: This is a specific segment of a full article that covers all license application issues. You can access that full article here.

Chiropractic physicians who are applying for a license based on existing licenses in other states should select – “Licensure by Endorsement” when downloading the license application.

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Endorsement licensure is often erroneously referred to as “reciprocity licensure,” but the two are not the same. Licensure by reciprocity occurs when one jurisdiction automatically issues a license based solely on the existence of licensure in another jurisdiction, regardless of the respective requirements for licensure in the two jurisdictions. However, to qualify for licensure by endorsement, not only must the applicant hold a license from one jurisdiction; the laws of the original jurisdiction and the jurisdiction of the new application must have been substantially equivalent at the time the original jurisdiction issued the license. Therefore, licensure by endorsement is not automatic and will not be granted without additional qualifications if there are significant differences in the laws of the two jurisdictions.

The Department may, in its discretion, issue a license by endorsement to any person who is currently licensed to practice as a chiropractic physician, in any other state, territory, country or province, upon submitting evidence satisfactory to the Department that: the applicant is of good moral character; that the applicant is physically, mentally and professionally capable of practicing medicine with reasonable judgment, skill and safety; that the applicant is a graduate of a chiropractic school or college approved by the Department at the time of his or her graduation; and that the requirements for the applicant’s license as a chiropractic physician are deemed by the Department to have been substantially equivalent to the requirements for a license to practice in Illinois at the dates of the applicant’s license. Applicants must also undergo a criminal background check.

The IDFPR has some discretion in endorsement applications and may evaluate each applicant on an individual basis. It may take into account, among other things, the extent to which the applicant will bring unique experience and skills to the State of Illinois. As part of its discretion, the IDFPR may require an endorsement applicant to successfully complete an examination as recommended by the Medical Licensing Board, i.e., in cases where the applicant has been licensed in a jurisdiction that does not require the NBCE examination (see number 5(A) below).

Each applicant currently licensed in another jurisdiction who applies to the IDFPR for a license in Illinois as a chiropractic physician by endorsement must cause to be sent to the IDFPR (68 Ill. Adm. Code 1285.80(d); Section 1285.80(d) of the Rules):

  1. A signed application on which all questions have been answered and all programs of chiropractic education attended by the applicant have been identified, including dates of attendance;
  2. An official transcript of the courses of instruction prerequisite to professional training in a college, university or other institution for those applying pursuant to Section 11(B)(2) of the Act;
  3. An official transcript and copy of diploma or official transcript and certification of graduation from the medical education program granting the degree; the transcript shall indicate that the applicant has met the minimum chiropractic education requirements of the Act;
  4. Proof that the applicant is of good moral character and has not engaged in any conduct or activities which would constitute grounds for discipline under Section 22 of the Act. Applications of individuals who answer affirmatively to any question on the personal history portion of the application or who have engaged in activities which would constitute grounds for discipline shall be forwarded to the Enforcement Division of the Division of Professional Regulation for further investigation and action by the Medical Licensing Board as provided in Section 9(B)(4) of the Act (see section on “Personal History” below):
  5. Successful completion of Part I, Part II and Part III of the examination administered by the National Board of Chiropractic Examiners. (Note: effective July 1, 2016, Illinois requires NBCE Part IV in addition to Parts I, II and III, so it is likely this portion of the rule will be revised to include a requirement for Part IV for any applicant whose licensure in the original jurisdiction was issued on or after July 1, 2016.)
    1. The Medical Licensing Board may, in its discretion and in individual cases where the applicable conditions of Section 19 of the Act have not been satisfied, make a recommendation to the Director to require an applicant to successfully complete the Special Purposes Exam for Chiropractors (SPEC) or Part III of the examination administered by the National Board of Chiropractic Examiners;
    2. The Medical Licensing Board may recommend a waiver of Part III of the examination or the SPEC requirement. In making the recommendation, the Licensing Board shall consider the quality of the chiropractic education and practical experience, including, but not limited to, whether he/she is Board Certified in a specialty, has achieved special honors or awards, has had articles published in recognized and reputable journals, has written or participated in the writing of textbooks in chiropractic and any other circumstance or attribute which the Medical Licensing Board accepts as evidence that the applicant has outstanding and proven ability in chiropractic;
  6. Certification from the jurisdiction of original and current licensure stating:
    1. The date of issuance of the license; and
    2. Whether the records of the licensing authority contain any record of any disciplinary action taken or pending;
  7. The fee required by Section 21 of the Act; and
  8. Verification of fingerprint processing from Illinois State Police (ISP), an ISP live scan vendor whose equipment has been certified by ISP, or a fingerprint vendor agency licensed by the Division. Out-of-state residents unable to utilize the ISP electronic fingerprint process may submit to ISP one fingerprint card issued by ISP, accompanied by the fee specified by ISP. Fingerprints shall be taken within the 60 days prior to application.
    1. Pursuant to Section 9.7 of the Act, the Division shall check the criminal background of each endorsement applicant through the Federation of State Medical Boards or Chiropractic Information Network-Board Action Database (CIN-BAD).
    2. When the accuracy of any submitted documentation or the relevance or sufficiency of the course work or training is questioned by the Division or the Medical Licensing Board because of lack of information, discrepancies or conflicts in information given, or a need for clarification, the applicant seeking licensure shall be requested to:
      1. Provide information as may be necessary; and/or
      2. Appear for an interview before the Licensing Board to explain the relevance or sufficiency, clarify information or clear up any discrepancies or conflicts in information.
    3. Within 60 days after issuance of the license, the physician shall complete a physician profile in accordance with 68 Ill. Adm. Code 1285.305 (Section 1285.305).

About Author

Adrienne Hersh, JD, ICS Legal Counsel

Adrienne serves as Illinois Chiropractic Society general counsel and provides legal advice and support on a wide range of legal issues affecting chiropractic physicians, including licensing and other health care regulations, scope of practice, insurance and reimbursement, business structuring, labor and employment, contracts, and litigation. Adrienne previously served for 8 years as general counsel to the Illinois Department of Professional Regulation (now the Division of Professional Regulation, Department of Financial and Professional Regulation), where she was chief legal counsel responsible for overseeing all legal issues and advising the 50+ licensing and disciplinary boards, including the Medical Disciplinary Board and the Medical Licensing Board. She is a member of the Illinois State Bar Association Health Care Section, the Illinois Association of Healthcare Attorneys, and the National Association of Chiropractic Attorneys.

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